Select Committee on Environment, Transport and Regional Affairs Appendices to the Minutes of Evidence

Memorandum by The Wildlife Trusts (IW 28)



  1.1  The Wildlife Trusts are a unique national partnership of 46 independent charities, the Urban Wildlife Partnership and Wildlife Watch, the junior branch.

  1.2  At a local level we are working to protect wildlife and natural places for future generations to enjoy. At a national level we join forces to influence decision-makers and put across our message. Together with more than 350,000 members, we form the largest voluntary group concerned with all aspects of wildlife conservation and environmental protection.

  1.3  Collectively, The Wildlife Trusts manage approximately 2,250 wetland habitats and 595 river reaches. Outside of our reserves the Otters and Rivers Project (OARP) deliver advice and practical expertise to riparian and wetland managers. In the past 18 months the OARP has carried out over 240 significant habitat enhancement schemes and visited over 740 landowners to provide habitat management advice. The Wildlife Trusts are strongly committed to the Biodiversity Action Plan (BAP) process, acting as a lead or joint lead partner for 23 Species Action Plans.

  1.4  Inland waterways are very valuable for our wildlife and present a precious environmental resource. The educational, recreational and amenity value of waterways rely on a high quality environment. It is the role of waterway authorities to protect and enhance this resource using strategic frameworks including the biodiversity planning process. In particular there should be no presumption in favour of development of waterways where this conflicts with the needs of wildlife.


  2.1  The management structure of inland waterways arose in an unco-ordinated fashion in response to the need to transport freight in the eighteenth and nineteenth centuries. Inland waterways are therefore managed by a wide range of organisations, which vary in structure, function and duties including those of conservation and wildlife protection. The three main navigation authorities responsible for three quarters of the navigable inland waterways (Broads Authority, British Waterways and the Environment Agency) all have clear conservation and environmental duties[2]. The remaining quarter of navigable inland waterways are managed by a wide range of other organisations, most of which have no statutory duty to further wildlife conservation.

  2.2  Currently the methods used and the standards applied to waterway management differ from authority to authority. The Wildlife Trusts would like to see the environmental practices of all navigation authorities brought in line with minimum environmental standards. The Wildlife Trusts would like a statutory code of environmental practice adopted as a standard throughout the industry with clear and specific references to furthering wildlife conservation in the water channel and along associated bankside habitats. Environmental codes of practice should provide guidance on addressing conflicts between the needs of recreation, navigation and conservation. We support the Association of Inland Navigation Authorities (AINA) role in producing and promoting standards of best practice for navigation authorities. The production of best practice strategies should be open to public consultation.

  2.3  Where restoration of a canal results in the creation of new navigation authorities or the expansion of a navigation network, the new authority should be given clear conservation duties and management of restored waterways should follow best practice guidelines.

  2.4  Rivers and streams are much more dynamic than built waterways and require very different management. However Waterways for Tomorrow does not make the distinction between natural and built waterways clear. The Wildlife Trusts support the role of the Environment Agency as the navigation authority on rives and encourage the incorporation of all non-built or "natural" waterways under Environment Agency control. We believe the structure of river management must integrate a range of functions such as navigation, flood defence, water resources, recreation and conservation. Holistic river management of this kind is best dealt with by the Environment Agency.


  3.1  See also paragraphs 2.2 and 2.4.

  3.2  Inland waterways are a precious environmental resource, for example, British Waterways manage land with over 100 SSSIs and more than 800 local Wildlife Sites. The educational, recreational and amenity value of waterways rely on the maintenance of a high quality environment. The conservation and amenity value of waterways is not restricted to the water channel, terrestrial habitats associated with waterways provide vital wildlife sanctuaries in both urban and rural habitats. It is the role of waterway authorities to protect and enhance this resource using strategic frameworks including the biodiversity planning process.

  3.3  The Wildlife Trusts support the "protection, conservation and enhancement" of waterway wildlife proposed in Waterways for Tomorrow,[3] however the proposals presented do not include targets or strategies for delivery of this commitment to wildlife conservation.

  3.4  Current common practices such as sheet-piling bank revetment to protect eroding banks have little or no wildlife value and are not commensurate with the duty of the three main navigation authorities to "further conservation". More wildlife-friendly erosion control measures such as coir fibre rolls and brushwood faggoting have been used on an experimental basis, for example the Kennet and Avon Canal. The Wildlife Trusts would like to encourage the use of more wildlife-friendly erosion controls and evaluation of their success. Effective methods should be promoted and adopted as a matter of course wherever practicable.

  3.5  The Trusts expect the Government to support the enhancement of wildlife habitat as part of all waterside development.3 We welcome the Government's encouragement of the re-use of previously developed land known as "brownfield" sites.[4] However, brownfield sites alongside waterways can have high wildlife value and provide a rare opportunity for the enjoyment of wildlife by the urban populace. The Wildlife Trusts regard it as vital that the planning process and planning policy guidance are used as vehicles for actively supporting waterside habitat enhancement projects during development works. We strongly support the establishment of a "blue belt" planning designation,[5] which makes specific reference to the wildlife value of inland waterways and associated habitats. This philosophy applies to the wider countryside, particularly in urban environments where the wildlife resource can be appreciated by millions of people. The Wildlife Trusts also support the provision of best practice guide to planners by Inland Waterways Advisory Council (IWAAC). This publication must stress the duties of planners to wildlife conservation and how this applies to both waterside development and waterway restoration.[6]

  3.6  The Wildlife Trusts support the Government in its encouragement of environmental enhancement of waterways.3 However, much current wildlife enhancement work is carried out as mitigation for habitat loss resultant from engineering and development works on waterway structures. We believe the Government should provide a framework for wildlife habitat enhancement strategies as part of all waterway management packages. The production of the habitat frameworks and waterway management strategies should be open to public scrutiny and consultative involvement, increasing local project ownership. To facilitate these strategies we would strongly recommend ring-fenced habitat enhancement funding to be included in any grant aid of the inland waterways system.

  3.7  Good water quality is central to many functions of waterways and is vital for wildlife, as such good or fair river-water quality is one of the Governments "headline indicators of sustainable development".[7] The water quality of canals is improving with over 75 per cent of canals in England and Wales with good or fair water quality.[8] However, there are regional differences and the water quality in some canals remains poor. The Wildlife Trusts support regular monitoring of canal water quality and believe that a reduction in pollution inputs in the waterways system should remain a top management priority.

  3.8  The Wildlife Trusts welcome the Governments encouragement of greener boating technology particularly electric and solar powered craft.3 The Government could further support the use of greener technology by setting firm targets for provision of least environmentally-damaging facilities on waterways and by providing grant aid and tax advantages for developments using this technology.

  3.9  The Wildlife Trusts welcome the production of guidance on notification and management of waterway SSSIs.[9] The guidance should be expanded to include reference to the management of local Wildlife Sites.


  4.1  Water is unique amongst natural resources; its presence and, in the case of waterways, its conduit of transport are of fundamental importance to the health of the environment and our quality of life.

  4.2  Inland waterways move water within and between catchments requiring both water abstraction and discharge throughout inland waterways. At present, abstraction for the purpose of navigation is exempted from control while transfers for public water supply require an abstraction license.

  4.3  The Wildlife Trusts welcome the Government proposal to bring abstractions for navigation under control through a system of "consents"[10] administered by the Environment Agency. We believe that such a system of regulation is essential if the management and restoration of waterways is to be carried out within the context of sustainable water resource development.

  4.4  The Government's proposals on the form of abstraction consents are non-prescriptive allowing the Environment Agency freedom to apply a greater range of conditions than the licensing system permits. While The Wildlife Trusts accept that a pragmatic approach must be taken in regulating many of these historic abstractions, consents must be sufficiently tightly drawn so as to protect the aquatic environment and allow meaningful enforcement. The formulation of consents should, like the licensing system, be subject to public scrutiny.

  4.5  Where canal restoration is proposed it must be recognised that the social, hydrological and ecological pressures within a supply catchment may differ vastly from those that existed at time of the original design. Existing restoration schemes have gone ahead without solutions to water supply problems; for example the use of the eastern link of the Basingstoke Canal is severely constrained by shortage of water for the locks each summer.[11] There must be no presumption that the renewal of historic abstraction practices will be sustainable in light of prevailing pressures.

  4.6  With reference to paragraphs 4.4 and 4.5 The Wildlife Trusts believe that the allocation of water resources for existing navigation, the restoration of historic canals or the construction of new waterways should be delivered through the Environment Agency's Catchment Abstraction Management Strategies (CAMS). There must be no presumption that abstraction for navigation should take priority over those of other water users or the needs of the environment.

  4.7  Transferring water between rivers and waterways for the purpose of human consumption and potentially creating a national water network would probably cause local, regional and national damage to important ecological communities, some of SSSI quality and supporting biodiversity action plan (BAP) species.

  4.8  Such transfers increase the potential for spread of alien invasive species, parasites and disease. Invasive aquatic species such as zander (Stizostedion lucioperca) predate native species such as roach and bream, which can be locally denuded with significant impacts to recreational usage and fisheries incomes. Zebra mussels (Dreissena polymorpha) can be spread via their motile larvae, coating water channels and causing severe and expensive damage to water supply pipeworks. Other invasive species grow vigorously and have no native predators. For example Japanese knotweed (Fallopia japonica) is able to cover vast stretches of riverbank whilst the aquatic species, floating pennywort (Hydrocotyle ranunculoides) and water fern (Azolla filiculoides) smother waterways. Diseases can accompany the spread of invasive species and present a threat to the survival of native species. The spread of non-native crayfish, for example has helped spread crayfish plague which now threatens the survival of the native white-clawed crayfish (Austropotamobius pallipes).

  4.9  Eighteenth century canals were not designed for the transfer of significant volumes of water. If increased flows and/or flow reversals are to be accommodated the hydraulic pinch points on the system, such as bridges and locks will require substantial re-engineering. The extensive works required will not only risk changing the character of our inland waterways but also inevitably disturb wildlife and possibly permanently damage aquatic and riparian habitats.

  4.10  In general the development of water transfer via waterways would do nothing to encourage demand management, or raise local awareness of the impacts of water use on the environment. In addition to direct impacts the pumping of water against hydraulic gradients, and the treatment of low quality water, is energy intensive and would lead to increased greenhouse gas emissions.

  4.11  In light of the above The Wildlife Trusts do not support increased water transfer and we believe the development of a national water grid is not compatible with the principles of sustainability or local accountability. The Government must move away from the "predict and provide" philosophy of the past and learn from European nations who have shown that a per-capita rise in water consumption is not inevitable and can actually be reversed.[12] The emphasis in water conservation must focus on effective demand management, leakage control[13] and the development of local water resources wherever this is compatible with long term sustainability.

  4.12  The Wildlife Trusts support proposed regulatory changes to allow the Environment Agency to compel water undertakers to enter into bulk supply agreements, or transfer abstraction rights, wherever this is consistent with their duty to secure the proper use of water resources, further conservation and contribute to sustainable development.[14] However we object to proposals to give similar powers to the Director General of Ofwat[15] whose primary duty is to promote economic efficiency and competition and has a history of affording less importance to environmental obligations.

  4.13  The Government must avoid any confusion over the authorisation and regulation of water transfers, and show its commitment to the UK BAP process by ensuring the Environment Agency remains the prime regulator for such schemes.

  4.14  The requirements of the Environmental Impact Assessment Directive[16] would have to be met for any large scale scheme involving inter-basin transfer of water. The Wildlife Trusts stress the need for full Environmental Impact Assessments (EIA) of all water transfer proposals and regard as essential the adoption of the "precautionary principle"[17] where effects on wildlife remain unclear.


  5.1  Appropriate restoration of disused and abandoned canals and other waterways can bring environmental, economic and recreational benefits to both rural and urban areas. However, Waterways for Tomorrow and other supporting documents contain an implicit presumption for restoration of currently un-navigated canals to navigation by powered craft.[18] There is little recognition of the high recreational and amenity value of some un-navigated canals when they are maintained for quiet recreational usage such as bird watching, walking, cycling, rowing and canoeing.

  5.2  Waterways for Tomorrow states "A moderate amount of boat traffic is . . . helpful in sustaining biodiversity on canals". However the case for increased biodiversity on navigated waterways with moderate boat traffic is unproven and no convincing evidence is presented in either Waterways for Tomorrow or the supporting documents.[19] The consequences to flora and fauna of restoring navigation to stretches of waterway with high wildlife value remain contentious. We would like the "precautionary principle" to be adopted, when assessing the potential impact of the restoration of motorised navigation on wildlife. The Wildlife Trusts would like to see further funding of research into the effects of canal restoration on wildlife and moratorium on increasing or reinstating navigation to sites of high wildlife value[20] until the results of these studies are available.

  5.3  See also paragraphs 2.3 and 4.5.


  6.1  The Wildlife Trusts support the increased use of waterside paths for all quiet recreational uses wherever this is compatible with wildlife conservation.[21]

  6.2  Angling is one of the most popular participation sports in the UK, with 100,000 people regularly fishing on British Waterways' canals.[22] The Wildlife Trusts support the rights of anglers wherever this is compatible with wildlife conservation. Codes of practice for fisheries and anglers are available[23] which encourage sustainable fisheries management. The Wildlife Trusts promote the adoption of similar codes of practice for all inland waterways but do not support the intensive stocking of fish to support artificially high population densities for angling purposes.

  6.3  See also paragraph 2.2.


  7.1  The Wildlife Trusts see the role of all inland waterway authorities as facilitating the recreational and commercial use of waterways, wherever this is compatible with the protection and enhancement of the waterway and waterside environment. The Wildlife Trusts believe the future of the waterway environment may be enhanced by:

    —  The adoption of statutory environmental duties and practices by all waterway authorities.
    —  Ring-fenced habitat enhancement funding.
    —  The use of more wildlife-friendly erosion control methods.
    —  Grant and tax aid to support the use of green technology.
    —  The establishment of a "blue belt" planning designation, for inland waterways.

  7.2  The Wildlife Trusts support the role of the Environment Agency as the navigation authority on rivers and encourage the incorporation of all non-built or "natural" waterways under Environment Agency control. The Wildlife Trusts also see the Environment Agency as the main regulator of water resource planning on inland waterways through CAMS. The Trusts believe there must be no presumption that abstraction for navigation should take priority over the needs of the environment.

  7.3  The Wildlife Trusts do not support large scale water transfer using the inland waterways network because:

    —  The large scale engineering works necessary to facilitate such water transfer may damage valuable wildlife habitats.

    —  Such transfers increase the potential for spread of alien invasive species, parasites and disease.

    —  Water transfer via waterways would do nothing to encourage demand management or raise local awareness of the impacts of water use on the environment.

    —  Pumping of water against hydraulic gradients and the treatment of low quality water are energy intensive and therefore not sustainable.

  7.4  The Wildlife Trusts would like the "precautionary principle" to be adopted when assessing the potential impact of water transfers, waterway development and restoration on wildlife habitats. Further funding of research into the effects of canal restoration on wildlife is required. The Wildlife Trusts would like a moratorium on increasing or reinstating navigation to sites of high wildlife value until the results of these studies are available.

Louise Bardsley

Freshwater Officer, and

Robert Cunningham

Water Policy Officer

September 2000

2   British Waterways has a duty to further conservation under subsection (1)a of the British Waterways Act 1995. The Environment Agency has a duty to further conservation under Part 1 of the Environment Act 1995, section 7(1)a. The Broads Authority has a duty to further conservation under section 2 of the Norfolk and Suffolk Broads Act 1988. Back

3   The proposals referred to are contained in paragraph 6.42 of Waterways for Tomorrow DETR 2000-the consultation document on the future of inland waterways. Back

4   Planning Policy Guidance Note Number 3: Housing (PPG3). DETR 2000. Back

5   A "blue belt" would provide the equivalent of green belt planning protection for inland waterways and the linear habitats associated with them. Back

6   Recommendations included in paragraph 6.73 of Waterways for Tomorrow DETR 2000. Back

7   The Governments strategy for sustainable development lists 150 indicators of sustainable development. A subset of 14 indicators were chosen to highlight changes in "the quality of life" in the UK-A Better Quality of Life HMSO 1999. Back

8   Water Management, Waterway Maps and Data Sheets British Waterways 1998. Back

9   Recommendations are included in paragraph 6.35 of Waterways for Tomorrow DETR 2000. Back

10   Taking Water Responsibly, paragraphs 3.10-3.22. Back

11   Waterway Restoration Priorities, Inland Waterways Amenity Advisory Council (IWAAC) 1998. Back

12   Reduction in Dutch per capita consumption reported in Demand Management Bulletin No 38, Environment Agency. Back

13   Avoiding waste of water and promoting consumption reductions are targets of the governments sustainable strategy document-A Better Quality of Life HMSO 1999. Back

14   Taking Water Responsibly, paragraph 9.11. Back

15   Competition in the Water Industry-consultation paper, paragraphs 6.8-6.11. Back

16   The Environmental Impact Assessment Directive (85/337/EEC as amended by 97/11/EC) sets out a procedure, which must be followed for certain types of project where they are likely to have a significant effect on the environment. Back

17   The governments strategy for sustainable living set the precautionary principle at the heart of a 10 point sustainable development plan-A Better Quality of Life, May 1999 paragraph 4.1. Back

18   Waterways for Tomorrow paragraphs 3.10-3.14, Waterway Restoration Priorities the report of the IWAAC June 1998. Britain's Inland Waterways: An Undervalued Asset IWAAC. March 1996. Back

19   Waterways for Tomorrow, paragraph 6.35, supporting document Code of Practice on Conservation, Access and Recreation DETR 2000. Back

20   Sites of high wildlife value include all European or nationally designated sites such as SACs and SSSIs as well as locally identified Wildlife Sites. Back

21   Waterways for Tomorrow, paragraph 6.16. Back

22   Waterways for Tomorrow, paragraph 6.1. Back

23   Freshwater Fisheries and Wildlife Conservation-a good practice guide Environment Agency 1998, Code of Conduct for Specialist Coarse Anglers Specialist Anglers Conservation Group 1997. Back

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